USA CUN16 SOIL Strawberry Fruit Open Field Page 1 of 11

NOMINATING PARTY: The United States of America

FILE NAME: USA CUN16 SOIL STRAWBERRY FRUIT Open Field 

BRIEF DESCRIPTIVE TITLE OF NOMINATION:

Methyl Bromide Critical Use Nomination for Preplant Soil Use for Strawberry Fruit Grown in Open 

Fields (Submitted in 2014 for the 2016 Use Season)

CROP NAME (OPEN FIELD OR PROTECTED): Strawberry Fruit Open Field

QUANTITY OF METHYL BROMIDE NOMINATED:

TABLE 1: QUANTITY OF METHYL NOMINATED

Year NOMINATION AMOUNT 

2016 231,540 kg

NOMINATING PARTY CONTACT DETAILS:

Contact Person: Federico San Martini, Ph.D.

Title: Foreign Affairs Officer

Address: Office of Environmental Policy

U.S. Department of State

2201 C Street, N.W. Room 2657

Washington, D.C. 20520 

U.S.A.

Telephone: (202) 647-3819

Fax: (202) 647-1052

E-mail: SanMartiniFM@state.gov

Following the requirements of Decision IX/6 paragraph (a)(1) The United States of America has determined that the 

specific use detailed in this Critical Use Nomination is critical because the lack of availability of methyl bromide for this

use would result in a significant market disruption. ■ Yes  No

Signature Name Date

Title: 

(Details on this page are requested under Decision Ex. I/4(7) for posting on the Ozone Secretariat website under 

Decision Ex. I/4(8).) 

This form is to be used by holders of single-year exemptions to reapply for a subsequent year’s exemption (for example, 

a Party holding a single-year exemption for 2005 and/or 2006 seeking further exemptions for 2007). It does not replace 

the format for requesting a critical-use exemption for the first time.

In assessing nominations submitted in this format, TEAP and MBTOC will also refer to the original nomination on 

which the Party’s first-year exemption was approved, as well as any supplementary information provided by the Party in 

relation to that original nomination. As this earlier information is retained by MBTOC, a Party need not re-submit that 

earlier information. 
USA CUN16 SOIL Strawberry Fruit Open Field Page 2 of 11

CONTACT OR EXPERT(S) FOR FURTHER TECHNICAL DETAILS:

Contact/Expert Person: Yu-Ting Guilaran

Title: Acting Director

Address: Biological and Economic Analysis Division

Office of Pesticide Programs

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W. Mailcode 7503P

Washington, D.C. 20460

U.S.A.

Telephone: (703) 308-0052

Fax: (703) 308-8091

E-mail: Guilaran.Yu-Ting@epa.gov

LIST OF DOCUMENTS SENT TO THE OZONE SECRETARIAT IN OFFICIAL NOMINATION PACKAGE:

1. PAPER DOCUMENTS: 

Title of paper documents and appendices

No. of pages Date sent to Ozone 

Secretariat

2. ELECTRONIC COPIES OF ALL PAPER DOCUMENTS: 

*Title of each electronic file (for naming convention see notes above)

No. of 

kilobytes 

Date sent to Ozone 

Secretariat

USA CUN16 SOIL STRAWBERRY FRUIT

* Identical to paper documents
USA CUN16 SOIL Strawberry Fruit Open Field Page 3 of 11

METHYL BROMIDE CRITICAL USE RENOMINATION FOR PREPLANT 

SOIL USE (OPEN FIELD OR PROTECTED ENVIRONMENT)

STRAWBERRY FRUIT

1. SUMMARY OF THE NEED FOR METHYL BROMIDE AS A CRITICAL USE 

This critical use exemption (CUE) nomination for methyl bromide (Table 1) is for strawberry 

production areas in California where there is a critical need for methyl bromide to treat fields 1) 

where a transition period is needed for the use of broadcast 100% chloropicrin in fields with high 

pest pressure, in particular, with Macrophomina and Fusarium (e.g., Koike and Bolda, 2013; Gordon 

et al., 2011) and 2) where 1,3-dichloropropene (1,3-D) is limited by township caps. While there is a 

critical need for methyl bromide through 2016, the U.S. methyl bromide nomination continues to be 

reduced and the 2016 nomination is the smallest amount yet nominated (Table 2). This sector will 

complete its transition to alternatives by the end of 2016, in time for the 2017 use-season (please see 

Appendix I—Transition Plan for California Strawberry Fruit Production).

2. SUMMARIZE WHY KEY ALTERNATIVES ARE NOT FEASIBLE

A critical use exemption for methyl bromide is needed for use in 2016 to allow additional time to 

implement commercial application of straight chloropicrin at rates up to 392 kg/ha (350 lb/acre) as 

well as other promising alternatives. Extensive research over the years by California scientists has 

indicated that alternative methods of treating soil should ultimately be able to manage key pests. 

However, a critical use of methyl bromide is needed for some additional time to work out practical 

and technical aspects associated with the application of high rates of straight chloropicrin, as well 

technical aspects affecting the efficacy of other alternatives such as anaerobic soil disinfestation 

(ASD) and steam. For example, results of recent studies show some problems, as well as the 

potential, of methyl bromide alternatives:

1. Inconsistency in application of fumigants has resulted in difficulties in managing important 

pathogens (apparent escapes) in some production locations. Recent research indicates, for 

example, that Macrophomina and Fusarium pathogens may not be fully exposed to 

fumigation treatments leaving infested strawberry crowns as a source of inoculum in 

fumigated fields (Daugovish et al., 2013a). Researchers found that inoculum below drip 

tapes in strawberry beds did not survive treatment with PicClor 60, but bed shoulder areas 

contained high levels of pathogens. Flat (broadcast) fumigation, which has been considered 

the most effective method of fumigation, provided 90% reduction of Macrophomina and 

79% reduction of Fusarium populations with 100% chloropicrin. Future research to address 

this issue will investigate how finely infested crowns should be broken down to allow

fumigants to kill pathogens, the effect of crop rotation and management, and the effect of 

increasing the number of drip tapes and their placement.

2. Anaerobic soil disinfestation (ASD) remains a potential non-chemical treatment whose 

efficacy continues to advance as research efforts evaluate the variables that affect its efficacy

(Shennan et al., 2013). Choices of organic matter, soil temperatures and the addition of 

nitrogen all affect efficacy in managing soil fungal pathogens. Inputs such as nitrogen and 
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some organic matter (e.g., rice bran) continue to be examined to determine if less expensive 

organic matter and reduced fertilizer applications can be effective. Daugovish et al. (2013b) 

found that insufficient anaerobic conditions may be partially responsible for ASD’s limited 

effect on soil pathogens in some studies (although in these tests final yield was comparable to 

chloropicrin treatments). This suggested that the method provided some beneficial effects on 

plant growth, especially early in the season. Conditions such as heavy soils with large soil 

clumps may allow Macrophomina and other soil-borne pathogens to escape from anaerobic 

conditions, and therefore, reduce the effectiveness of the control method.

3. A limited-time exemption for methyl bromide is critical to allow further innovations in the 

efforts to commercialize soil treatment with steam. Studies with steam-generating prototypes 

indicated that progress has been made toward commercialization of steam soil disinfestation

(Fennimore et al., 2013). Steam and steam + mustard seed meal gave positive results when 

yields, weed control, Pythium control, and improved nitrogen availability were measured. 

Costs of steam were considered comparable to methyl bromide treatments given a certain 

price of fuel, and returns exceeded costs of steam treatments. Further work is needed to 

develop equipment, to improve methods of applying the steam under various field conditions

(including reduced application time), and to ensure the commercial viability of this method.

4. Klonsky et al. (2013) found that there is potential to increase net revenue with steam as 

applicators learn how to use the new technology more efficiently. This learning phase would 

result in a shorter application time and decreased costs. Overall, steam shows promise as a 

fumigant, especially in large buffer areas where costs and returns have been shown in study 

plots to be comparable to chemical fumigants. However, because steam is an energyintensive technology, the price of fuel (usually propane) greatly influences the economic 

feasibility. Other factors impacting the cost of steam include machine cost (e.g., machine 

manufacturer's costs, repair costs, hours of life, and hectares treated per year) and operating 

costs (e.g., liters per treated hectare, labor hours and cost per hour, and transportation of 

steam machine). For small areas to be treated, transportation costs for steam application may 

be prohibitive. In addition, steam applicators have not been approved for commercial use by 

the U.S. Occupational Safety and Health Administration (OSHA). At present secondgeneration prototype applicators are under development.

3. IS THE USE COVERED BY A CERTIFICATION STANDARD?

There is no certification standard for strawberry fruit production.
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4. PROPORTION OF CROP USING METHYL BROMIDE 

TABLE 2. PROPORTION OF TOTAL HECTARES WHERE METHYL BROMIDE IS A CRITICAL NEED

REGION WHERE METHYL 

BROMIDE USE IS REQUESTED

TOTAL CROP 

AREA1(HA)

AREA NOMINATED FOR 

METHYL BROMIDE USE 

IN 2016 (HA)

PROPORTION OF TOTAL 

CROP AREA TO BE 

TREATED WITH CUE

METHYL BROMIDE (%)

California 15,240 1362 9.0

1 California Strawberry Commission 2013 Survey showed a total production of 40,192 acres (16,265 ha), less organic

production acres (2532 acres; 1,025 ha) (http://www.calstrawberry.com/commission/asurvey.asp)

5. IF PART OF THE CROP AREA IS TREATED WITH METHYL BROMIDE, INDICATE 

THE REASON WHY METHYL BROMIDE IS NOT USED IN THE OTHER AREA, AND 

IDENTIFY WHAT ALTERNATIVE STRATEGIES ARE USED TO CONTROL THE 

TARGET PATHOGENS AND WEEDS WITHOUT METHYL BROMIDE THERE.

Methyl bromide is not used on the majority of strawberry production fields (Table 2). Alternatives 

are effective and currently used 1) on soils where alternatives have been effective and/or where soils 

have below-threshold pathogen populations so that disease impact on fruit production is low, 2) on 

soils where township caps do not restrict 1,3-D use, and 3) on soils where broadcast 100%

chloropicrin has been effective.

Regulations in California

Currently all of the county agricultural commissions where strawberry fruit is grown now have a 

process in place to allow the use of chloropicrin at rates of up to 392 kg/ha (350 lb/acre). The 

specific location, topography, and proximity to sensitive sites will impact the granting of a permit. 

The use of up to 392 kg per ha of chloropicrin can provide enhanced efficacy where plant pathogens 

are difficult to control. The California Department of Pesticide Regulation (Cal DPR) is currently 

reviewing the registration of chloropicrin and 1,3-D. Cal DPR revisions of the regulations on the use 

of chloropicrin and 1,3-D (e.g. buffers, reentry intervals, tarps, use rate, etc.) could occur before 

2016. In addition, a review of 1,3-D could lead to changes in how the 1,3-D township caps are 

calculated.

6. WOULD IT BE FEASIBLE TO EXPAND THE USE OF THESE METHODS TO COVER 

AT LEAST PART OF THE CROP THAT HAS REQUESTED USE OF METHYL 

BROMIDE? WHAT CHANGES WOULD BE NECESSARY TO ENABLE THIS?

For the remainder of strawberry production where methyl bromide is considered critical, the final

transition from methyl bromide will be effective as of the 2017 use-season. For specifics regarding 

the transition from methyl bromide, please see Appendix I—Transition Plan for California 

Strawberry Fruit Production. 
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7. ECONOMIC FEASIBILITY OF ALTERNATIVES 

Net revenue is calculated here as gross revenue minus operating costs. This calculation is known as 

a partial budget analysis and is a good measure to describe the direct losses of income that may be 

suffered by the users. The net revenue presented here does not represent net income to the users. 

Net income, which is an indication of the profitability of an operation of an enterprise, is gross 

revenue minus the sum of operating and fixed costs. Net income should be smaller than the net 

revenue measured in this study. Fixed costs were not included because they are often difficult to 

determine and verify.

Summary of Economic Feasibility

The critical need for methyl bromide is for strawberry production land where1) a transition period is 

needed for the use of broadcast 100% chloropicrin, especially to control Macrophomina and 

Fusarium and 2) 1,3-D use is limited by township caps. The economic analysis of strawberry fruit 

production compared data on yields, crop prices, revenues and costs using methyl bromide and using 

alternative pest control regimens in order to estimate the loss of methyl bromide availability. The 

primary fumigant alternatives are 1,3-D/chloropicrin (225/123 lb/acre; 252/138 kg/ha) (e.g., Pic-Clor 

60, 33 gal/acre; 310 l/ha) or chloropicrin at 300-350 lb per acre (336-392 kg/ha). Pic-Clor 80 is not 

registered for use in the United States.

The economic analysis (see Table 3) indicates fumigant-treated soils can result in gains or losses to 

net revenues that range from -29% (with drip Pic-Clor 60) to 2% (with 100% broadcast 

chloropicrin), based on the cost of the individual fumigant and estimated yield loss. For the 2012-13 

growing season, chloropicrin has been approved for use in all production areas at a maximum rate of 

350 lb per acre (392 kg per ha), although county permits are subject to change. Technical and 

regulatory issues reduce the feasibility of 1,3-D use for a portion of strawberry production fields in 

California. 

The economic factors that support the critical need for methyl bromide for nominated areas are 1) 

where additional time is needed to transition to high rates (393 kg/ha) of straight chloropicrin, 2) 

regulations restrict the use of 1,3-D, 3) where increased production costs are incurred for 

alternatives, 4) where there are additional pest control requirements due to the lower efficacy of 

alternatives, and/or 5) where there are resulting shifts in other production or harvesting practices and 

yield losses. The feasibility of alternatives as compared to methyl bromide is dependent on 

maintaining yield and fruit quality at a competitive cost. 

Measures Used to Quantify the Impacts of a Loss of Methyl Bromide

Crop budgets were to determine the likely economic impact if methyl bromide were unavailable. 

Various measures were used to quantify the impacts, including the following: 

(1) Loss per Hectare. For crops, this measure is based on yield impact and closely tied to income. 

It is relatively easy to measure, but may be difficult to interpret in isolation.

(2) Loss/Gain per Kilogram of Methyl Bromide. This measure indicates the value of methyl 

bromide to crop production and is calculated by multiplying the loss/gain of methyl bromide by the 
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number of fumigation cycles (i.e., one) and then dividing the quantity by the number of kilograms of 

methyl bromide used to treat a hectare.

(3) Loss as a Percentage of Gross Revenue. This measure has the advantage that gross revenues 

are usually easy to measure, at least over some unit, e.g., a hectare of land or a storage operation. 

However, high-value commodities or crops may provide high revenues, but may also entail high 

costs. Losses of even a small percentage of gross revenues could have important impacts on the 

profitability of the activity.

(4) Loss as a Percentage of Net Operating Revenue. Net cash revenues are defined as gross 

revenues minus operating costs. This is a very good indicator of the direct losses of income that may 

be suffered by the owners or operators of an enterprise. However, operating costs can often be 

difficult to measure and verify.

(5) Operating Profit Margin. Operating profit margin is defined as net operating revenue divided 

by gross revenue per hectare. This measure would provide the best indication of the total impact of 

the loss of methyl bromide to an enterprise. Again, operating costs may be difficult to measure and 

fixed costs even more difficult. However, fixed costs are considered to be identical for all 

alternative scenarios, therefore, fixed costs were not included in the analysis.

These measures represent different ways to assess the economic feasibility of methyl bromide 

alternatives for strawberry fresh fruit producers. Because producers (suppliers) represent an integral 

part of any definition of a market, the threshold of significant market disruption is met if there is a 

significant impact on commodity suppliers using methyl bromide. These economic measures 

provide the basis for making that determination. 

The analysis presented in Table 3 compares the costs of three different fumigation options and a 

steam treatment to the cost of treating with methyl bromide. The analysis compared the impacts 

between the baseline methyl bromide and the alternatives which include: steam, broadcast 

chloropicrin at 300 pounds per acre, broadcast 1,3-D plus chloropicrin (Pic-Clor 60 (59/39)), and 

drip-applied 1,3-D plus chloropicrin (Pic-Clor 60 (56/37)). Costs consist of all operating costs 

including labor, equipment, application, and material. Yield losses may be 5% for soils treated with

Pic-Clor 60 drip or broadcast applications based on field observations, due to the increased 

prevalence of disease. Where township caps limit the use of 1,3-D, losses could be as high as 13%, 

according to the California Strawberry Commission.

Steam is a promising option and California researchers are experimenting with mobile and stationary 

steam applicators (Shennan et al., 2013; Fennimore et al., 2013; Klonsky et al., 2013). The analysis

presented below (Table 3) is based on small plot production (4 ha or less) and, therefore, may not be 

an accurate scenario for larger commercial-scale production. The cost of fuel is the primary driver 

for the cost of steam. Current diesel prices in California average around $4.25 per gallon as quoted 

by Pricelock.com on December 3, 2013 (www.pricelock.com/index).
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TABLE 3. ECONOMIC IMPACTS OF METHYL BROMIDE + CHLOROPICRIN, STEAM, 

CHLOROPICRIN, AND BROADCAST AND DRIP-APPLIED 1,3-D + CHLOROPICRIN

**Note that the measures in the tables above must be interpreted carefully. Operating costs do not include fixed costs 

and net revenue equals gross revenue minus operating costs. Values may not calculate exactly due to rounding during 

conversion from $/lb to $/kg.

*** Based on small plot production (4 ha or less); may not be an accurate scenario for larger commercial-scale

production. 

CALIFORNIA FRESH 

STRAWBERRY

METHYL 

BROMIDE + PIC

50/50

STEAM***

CHLOROPICRIN 

@300 LB/A

BROADCAST

PIC-CLOR 

60 GPA

BROADCAST

PIC-CLOR 

60 EC 25

GPA DRIP

PRODUCTION LOSS (%) 0% 0% 0% 5% 5%

 PRODUCTION PER HECTARE 

(KG/HA)

50,091 50,091 50,091 47,586 47,586

**PRICE PER UNIT (US$) $3.17 $3.17 $3.17 $3.17 $3.17

= GROSS REVENUE PER 

HECTARE (US$) $159,021 $159,021 $159,021 $151,070 $151,070

- OPERATING COSTS PER 

HECTARE (US$)** $132,562 $132,513 $131,142 $131,383 $127,818

= NET REVENUE PER 

HECTARE (US$) $26,459 $26,508 $26,879 $19,687 $23,252

*LOSS MEASURES *

1. LOSS/GAIN PER HECTARE 

(US$) $0 $49 $420 $ (6,822) $(3,207)

2. LOSS/GAIN PER KILOGRAM 

OF METHYL BROMIDE (US$) $0 $0.29 $2.47 $(40.12) $ (18.86)

3. LOSS/GAIN AS A 

PERCENTAGE OF GROSS 

REVENUE (%)

0% 0% 0% -4% -2%

4. LOSS/GAIN AS A 

PERCENTAGE OF NET 

OPERATING REVENUE (%)

0% 0% 2% -26% -12%

5. OPERATING PROFIT 

MARGIN (%) 17% 17% 17% 13% 15%
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8. RESULTANT CHANGES TO REQUESTED EXEMPTION QUANTITIES

The USG has applied a transition rate to the alternatives, which is reflected in the nomination 

amount and detailed in Table 4. The amount requested reflects time to transition to straight 

chloropicrin at the recently approved high-use rates, adjustments for areas with high pest pressure, 

1,3-D/chloropicrin (TeloneTM) township caps, and local regulatory restrictions on the use of 

chloropicrin. 

TABLE 4. NOMINATION AMOUNT: 

STRAWBERRY FRUIT 

 California Strawberry 

Commission 

Quantity Requested for 2015: Amount (kgs) 373,660

Quantity Recommended by 

MBTOC/TEAP for 2015 : Amount (kgs) 373,660

Amount (kgs) 373,660

Area (ha) 2,198

Rate 170

Transition from 2015 

Baseline Adjusted Value

Percentage (%) 38%

Amount (kgs) 231,540

Area (ha) 1,362

Rate 170

SECTOR

Quantity Authorized by 

Parties for 2015:

Quantity Required for 

2016 Nomination:
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9. CITATIONS

Daugovish, O., Gordon, T., Koike, S., Subbarao, K. 2013a. Fusarium oxysporum and 

Macrophomina phaseolina persistence in fumigated soil and management approaches.

International Research Conference on Methyl Bromide Alternatives and Emissions Reductions 

(2013). http://mbao.org/2013/Proceedings/66DaugovishOPathogen%20persistence.pdf

Daugovish, O., Fennimore, S., Gordon, T., Koike, S., Muramoto, J., Shennan, and C., Subbarao, K. 

2013b. Non-fumigant treatments for management of Fusarium oxysporum and Macrophomina 

phaseolina on strawberry cultivar San Andreas. International Research Conference on Methyl 

Bromide Alternatives and Emissions Reductions (2013).

http://mbao.org/2013/Proceedings/18DaugovishO%20treatmentssummary.pdf

Fennimore, S. Miller, T., Goodhue, R., Dorn, N., Broome, J., Muramoto, J., Shennan, C. and Martin, 

F. 2013. Evaluation of an automatic steam applicator in strawberry: 2012-13 results. Annual 

International Research Conference on Methyl Bromide Alternatives and Emissions Reductions 

(2013). http://mbao.org/2013/Proceedings/11FennimoreS.pdf

Gordon, T. R., Koike, S. T., Daugovish, O., Shaw, D. V., and Larson, K. D. 2011. A comprehensive 

approach to management of wilt diseases caused by Fusarium oxysporum and Verticillium 

dahlia. California Strawberry Commission Annual Production Research Report. 

http://www.calstrawberry.com/fileData/docs/Gordon_2010_11_Mac_Fus.pdf

Koike, S. and Bolda, M. 2013. Charcoal rot of strawberry: Increasing problem in California. 

University of California Extension. 

http://ucanr.edu/blogs/blogcore/postdetail.cfm?postnum=11043

Klonsky, K., Goodhue, R., Xu, Y., Fennimore, S., Shennan, C., and Muramoto, J. 2013. Economic 

feasibility of non-fumigant systems in CA strawberry buffer zones. Annual International 

Research Conference on Methyl Bromide Alternatives and Emissions Reductions (2013).

http://mbao.org/2013/Proceedings/17KlonskyK.pdf

Shennan, C., Muramoto, J., Baird, G., Koike, S., Bolda, M., and Mazzola, M. 2013. Optimizing 

anaerobic soil disinfestation for soilborne disease control. Annual International Research 

Conference on Methyl Bromide Alternatives and Emissions Reductions (2013).

http://mbao.org/2013/Proceedings/13ShennanC.pdf
USA CUN16 SOIL Strawberry Fruit Open Field Page 11 of 11

APPENDIX I.

Transition Plan for California Strawberry Fruit Production

The transition from methyl bromide (Appendix Table 1) has been undertaken as research and 

experience has led to the effective use of alternative methods of pest management. County 

agricultural commissioners have been observing the effect of broadcast applications of high rates of 

chloropicrin on large tracts of land that have transitioned from methyl bromide. The shift of 

production away from sensitive sites and the necessity to incorporate any new restrictions for 

chloropicrin currently being considered by Cal DPR require the optimization of practices and 

techniques that will ensure the long-term efficacy of broadcast applications of straight chloropicrin 

to manage the soilborne disease issues in California.

Appendix Table 1. Transition from methyl bromide use (2012 to 2017) for California 

strawberry fruit.

CUE Requests, Transitioned, 

Nominated & Granted

Use Season

2012 2013 2014 2015 2016 2017

MB nominated (kg) 749,055 531,737 415,067 373,660 231,540 0

Hectares nominated 4,406 4,406 2,442 2,198 1,362 0

MB granted (kg) 673,085 461,186 415,067 373,660 --- ---

Hectares granted 4,421 2,713 2,442 2,198 --- ---